508 F. App'x 53
2d Cir.2013Background
- Matta, diagnosed with various forms of bipolar disorder, has not worked since 2005 and was hospitalized twice for manic episodes (Aug/Sep 2005).
- He filed for Social Security benefits on January 5, 2007 claiming disability from work.
- An ALJ denied benefits on January 26, 2009, finding plaintiff not disabled during the period at issue.
- The district court affirmed the ALJ’s decision on October 19, 2011.
- On appeal, the Second Circuit reviewed the record de novo for substantial evidence and legal standards, and affirmed.
- The court addressed the ALJ’s residual functional capacity (RFC) finding, conflicting medical opinions, and the treatment history.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the ALJ properly determined RFC and disability. | Matta argues the RFC is not supported by medical evidence and that bipolar fluctuations were not properly accounted for. | Astrue contends the ALJ weighed all evidence, including treating and consulting sources, and reasonably found a RFC compatible with regular work. | Yes; the ALJ’s RFC finding is supported by substantial evidence and properly weighed the medical opinions. |
Key Cases Cited
- Richardson v. Perales, 402 U.S. 389 (U.S. 1971) (conflict in medical evidence resolved by fact-finder; substantial evidence standard)
- Moran v. Astrue, 569 F.3d 108 (2d Cir. 2009) (definition of substantial evidence that supports agency's decision)
- Zabala v. Astrue, 595 F.3d 402 (2d Cir. 2010) (de novo review of substantial evidence and legal standards)
- Burgess v. Astrue, 537 F.3d 117 (2d Cir. 2008) (treating physician opinions may be discounted when not consistent with other substantial evidence)
- Halloran v. Barnhart, 362 F.3d 28 (2d Cir. 2004) (treating physician opinions need not be controlling if inconsistent with other evidence)
- Clark v. Comm’r of Soc. Sec., 143 F.3d 115 (2d Cir. 1998) (reasonableness of departing from a treating-source opinion)